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Global Regulatory Strategies and Best Practices Ask Me Anything Session

  • 1.  Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:30
    Hi Members,

    Recently, RAPS released it's quarterly article series focusing on global regulatory strategies and best practices. Today, we are joined by four experts, @Allison Komiyama, @Emily Huddle, Kirsten Messmer, and @Melissa Walker ,who will be discussing the articles in real-time and available to answer your questions.

    Please use this thread to ask the experts your questions.

    Can't wait to read the discussions!

    Best,
    Emily​​​​​​​​​​​​​

    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------


  • 2.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:33
    ​Hello everyone,

    Kirsten and I are looking forward to participating in the session today and answering any questions you may have regarding RI!

    ------------------------------
    Emily Huddle
    ------------------------------



  • 3.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jun-2019 13:37
    This message was posted by a user wishing to remain anonymous

    Hello - looking for advice on any tools (i.e. Cortellis, Freyr, RISYS, etc.) have the most benefit and output?


  • 4.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:42
    ​Hi,
    Thanks for being brave and asking the first question! There are tons of free resources to help you stay informed- Federal Register, FDA news subscriptions. In terms of paid subscriptions, Pink Sheet, Prevision Policy Clips, and RAPS News are very helpful to me. Cortellis is the RI database that I am most familiar with to help with RI related queries I receive.

    ------------------------------
    Emily Huddle
    ------------------------------



  • 5.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:46
    ​Hi, just to expand on Emily's response, the tools depend on what you are looking for. If you are looking to look at products that are under deveopment or in clinical trials Pharmaprojects is great, if you would like to find out in which countries a product is approved, then that would be Newport. Cortellis is good for regulatory summaries and translation from foreign languages. But all of those cost money, but are worth it. If you are looking for free resources, I might also suggest the Reg Recon from RAPS - it's a daily update with news affecting the drug development sphere. Also EMA has a what's new site where a lot of infomation it is posted. If you like to elaborate more what you would like the tools to do, maybe we can narrow it down some.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 6.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jun-2019 13:53
    This message was posted by a user wishing to remain anonymous

    Thanks for the feedback thus far. I am specifically speaking of paid services that would allow for monitoring and tracking of medical device-related Reg Intel/Reg changes, etc.


  • 7.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:02
    Hello Anonymous,
    Happy to share info on this topic if you will send me a separate message.
    Cheers,

    ------------------------------
    Melissa Walker RAC
    President & CTO
    St Louis MO
    United States
    ------------------------------



  • 8.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 13-Jun-2019 15:13
    This message was posted by a user wishing to remain anonymous

    Hi Anonymous,
    Here's an article from Focus that lists some good resources - https://www.raps.org/regulatory-focus™/news-articles/2017/2/regulatory-intelligence-tools-compendium-2017. The table in the article lists tools specifically for devices.


  • 9.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:48
    ​Hello, I read in the article that Regulatory Intelligence can be documented manually using Excel as a starting point.  How can I show that keeping such database is useful for the company?

    ------------------------------
    Delhy Arias ASQ-CQA, BS, MS
    Miami FL
    United States
    ------------------------------



  • 10.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:54
    ​Hello,
    At PPD we collect a lot of regulatory intelligence in spreadsheets that are answering specific questions for specific trials. The value lies in being able to adapt this at a later stage by adding further informatoin/updates and cherry picking applicable information for other applications. So, work done can be recycled. It's very easy to adjust. However, it needs to be updated on a regular basis. We also use these tables as starting point to enter the information into our internal regulatory affairs database - so work isn't lost since that informatoin is the initially presented as a table in that database.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 11.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:01
    Edited by Emily Huddle 12-Jun-2019 14:01
    ​Hi Delhy,
    Thanks for your question. My company is larger, so we have a dedicated, in-house system for capturing, communicating, and archiving RI. However, I still find Excel a very useful tool for capturing specific types of RI. For example, I also am responsible for monitoring competitor updates and maintain a spreadsheet, grouped by therapeutic area on different tabs, to capture important competitor regulatory milestones (marketing submissions, approvals, CRLs, etc.). Excel is a very user-friendly, economical way to capture and archive large amounts of data and could potentially be used to archive RI alerts/communications.

    ------------------------------
    Emily Huddle
    ------------------------------



  • 12.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:19
    As noted in Richard's article, many companies do not have departments or dedicated resources for RI.  If you set up a system for yourself, identify the key sources you need to monitor.  For those sources that have less frequent changes, make sure you are signed up on any email updates offered.  
    Keep to a reasonable number when picking frequent (weekly?) checking - like guidance documents, standards, and even product approvals.  Too many sources can become hard to keep up with.  I have seen some excellent internal systems started, but fail when time gets short and it cannot be updated. 

    Also suggest that when you have a system established, communicate important changes internally.  The best way to show value of the time you spend monitoring/generating RI is give others a "heads up" so surprises are minimized.

    ------------------------------
    Melissa Walker RAC
    President & CTO
    St Louis MO
    United States
    ------------------------------



  • 13.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 13-Jun-2019 15:12
    This message was posted by a user wishing to remain anonymous

    Hello

    Thank you for this open forum. A lot of questions about eIFUs. EU regulation allows having eIFU, but in practice there is a restriction to still having the IFU in paper form, assuring the user/patient have the information without depending on internet. Is there a way to completely eliminate the IFU in paper form? If not, is there a possibility to have a mix, paper form only in English, for example, and the another languages in the website or in a storage data key?
    Could you advice on this topic?

    Thank you!



  • 14.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:36
    Hi RegEx!
    We're ready for all your pressing questions!  Excited to be "asked anything" by this forum.

    ------------------------------
    Allison Komiyama
    AcKnowledge RS
    San Diego CA United States
    www.acknowledge-rs.com/regulatoryaf
    ------------------------------



  • 15.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:48
    Hello and Many Thanks to Emily Stamm and RAPS for hosting this session.

    My question is in regards to CAPA processes in relatin to ISO 13485:2016, ISO 14971, 21 CFR 820, and now MDSAP.  Risk management is a key element to be integrated into a company's risk management plan.  Furthermore, FDA, Health Canada and other regulatory bodies expect risk to incorporated as part of a CAPA system.  Taking into account these multiple systems, how would the panel suggest integrating risk management as part of a company's CAPA process?

    Thank you so much,

    Grace Powell

    ------------------------------
    Grace Powell
    Regulatory/Quality Assurance Manager
    Monroe WA
    United States
    ------------------------------



  • 16.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:28
    Grace,
    Great question!  The CAPA process should be a key part of the company's risk management process.  How it is implemented specifically will depend on the size of the company and the complexity/risk level of the product.  If you have any more details, would be happy to give you any suggestions from my experience.

    ------------------------------
    Melissa Walker RAC
    President & CTO
    St Louis MO
    United States
    ------------------------------



  • 17.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 13:51
    RI Advice for Small Companies

    @Emily Huddle and Kirsten Messmer: Your article focused on (and gave great insight into) regulatory intelligence "communication approaches for medium to large companies." For small companies (some having only 1-2 employees) who might not even have a regulatory person on staff, what tips do you have so that they can keep up with RI for their specific technology?
    ​​

    ------------------------------
    Allison Komiyama
    AcKnowledge RS
    San Diego CA United States
    www.acknowledge-rs.com/regulatoryaf
    ------------------------------



  • 18.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:02
    Hello Alison, great questions. It is really tough for small companies to keep up. Outsourcing and perhaps subscribing to a newsletter might help with that. Regulatory, particularly on the global basis, is very fast moving. So for a small company to keep up can be difficult. If the company, say has less than 50 employees, it is still possible to do these things in house, by having maybe one person watching what is going on in the relevant areas. Actually, ERA Consulting, the company I worked for before PPD, we only had 30 employees and it was part of my responsibility to keep a regulatory intelligence newsletter. Last year at RAPS, I hosted a solution circle on Regulatory Intelligence and it was a very lively discussion on about how companies of various si​zes handle regulatory intelligence and communication. Most smaller ones did keep each other informed with emails such as 'have you seen this update', 'this will be important for us' etc. It depends on the company culture and of course size. Perhaps for smaller companies looking into free webinars might also be a good way to keep up on RI - one watches the seminar and then share is with colleagues. But you are right our article mostly is approaches for larger companies that can have dedicated employees. @Emily Huddle feel free to fill in.


    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 19.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:10
    ​In addition to Kirsten's suggestions, keep in mind that Regulatory Agencies have mailing lists you can subscribe to, RSS feeds, Twitter accounts- many ways to keep up to date. There is also a way to sign up to receive alerts via Google, based on specific search terms and parameters. These are some examples of ways to "automate" receipt of publically available information that can be incredibly helpful in monitoring the regulatory/competitive environment.

    ------------------------------
    Emily Huddle
    ------------------------------



  • 20.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jun-2019 14:08
    This message was posted by a user wishing to remain anonymous

    @Allison Komiyama, I heard you in the pre-submission webinar hosted by FDA yesterday. During the Q&A session, you mentioned that in a few cases FDA was open to companies sending in multiple pre-submissions concurrently. Can you explain when that has been useful to get FDA feedback and when it is discouraged?


  • 21.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:25
    I thought FDA did a great job yesterday during the pre-sub webinar (they mentioned that the slides and transcript would be posted next week). My comment was to the two callers who asked about submitting multiple supplements and/or submitting a pre-sub for a device that might have indications spanning two branches. There are times when we do submit multiple pre-submission supplements, namely when the lead reviewer has suggested that is an acceptable option. In those cases, for example, we might submit one pre-sub that includes the biological risk assessment and summary of biocomp testing that has been done, and one pre-sub that perhaps includes the clinical protocol. These two pre-subs will likely be triaged by the lead reviewer to the biocompatibility reviewer and medical officer on your file, respectively. Since they are going to different consults, FDA has been accepting of two pre-subs at the same time. My main suggestion is that you don't ask for two face-to-face meetings for both meetings as a telecon or written feedback alone should be sufficient.

    I've been part of a few meetings where FDA has brought in representatives from multiple branches to address the multiple potential indications of a device. This can be very valuable as different branches might have insight into what pathway might be more direct for a company. Additionally, they might reduce burden by suggesting testing that could span the indications and save a company some time and money.

    I would discourage sending in multiple pre-subs when you've simply forgotten to ask something in your previous pre-sub and want to try to tack on more questions or data. While FDA allows multiple pre-submissions for a device, you can wear our your welcome if not careful!

    ------------------------------
    Allison Komiyama
    AcKnowledge RS
    San Diego CA United States
    www.acknowledge-rs.com/regulatoryaf
    ------------------------------



  • 22.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jun-2019 14:15
    This message was posted by a user wishing to remain anonymous

    Since regulatory intelligence is such a wide field with all the new developments, do you specialize in a specific area or try to keep up with really everything?


  • 23.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:23
    ​At my present company, RI is a global group of three FTEs. I am responsible for monitoring the US, Canada, and Japan. (I don't know Japanese, so coordinate with the Japan office for assistance in providing translated material.) My colleagues are responsible for EU and RoW. It is important to understand the regulatory priorities within your company to ensure you are focusing your efforts of the most important regulatory news. Of course, priorities shift, so an open dialogue with key stakeholders on a routine basis is very important. There is a lot of news/information to "filter out", but that is the advantage of having dedicated staff with the time to devote towards "filtering" and communicating the items of critical importance to an organization.

    ------------------------------
    Emily Huddle
    ------------------------------



  • 24.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:32
    Good point on following company priorities. PPD has a regulatory intelligence team of about 5-10 people and we cover global, but we also have specilists in about 50 countries where the RI function is part of their regulatory affairs role. I guess questions for our regulatory team are a little broader since we are a CRO and handle likely more breadth of products than Emily's company. ​

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 25.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:23
    Generally, I would see in my work at PPD, questions for the regulatory intelligence professional can come from any area of biopharma and/or medical device regulations. However, there is not way to 'know it all' - at PPD we have experts in certain fields and certain countries that provide specialized input. Personally, I have focused and remain up to date on biosimilars - it was the 'Hot Topic' around the time that the first biosimilar was approved in the US. I spoke at the RAPS Convergence about biosimilar regulations last year. My top specialty has always been and will remain gene and cell therapy - I worked in this field at the bench, so have hands on experiences. One Biotech I worked for in the past was developing neuronal progenitor cells for spinal cord injury and I have done some research into the genetics of Huntington's and Parkinson's disease. Of course in recent years, cell and gene therapies, including CAR T-cells have really taken off as valuable therapies. Regulators keep us on the toes also - providing frequent updates to frameworks and guidances. The other focus are for me is real-world evidence and the implementation into regulatory decision making. To sum it up, although I am responsible for collating regulatory intelligence on any topic as needed, I do specialize in the fields of biosimilars, advanced therapies and real-world evidence. ​

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 26.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:34
    At my company we are a team of seven and focus very specifically in US regulatory affairs for medical devices. I find there is plenty to keep up with in just that niche as FDA seems to update things almost daily! One way I gather our RI is from the FDA subscription service: https://updates.fda.gov/subscriptionmanagement
    A word of caution though...don't sign up for them all or you'll likely get 100s of emails a day!

    ------------------------------
    Allison Komiyama
    AcKnowledge RS
    San Diego CA United States
    www.acknowledge-rs.com/regulatoryaf
    ------------------------------



  • 27.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    This message was posted by a user wishing to remain anonymous
    Posted 12-Jun-2019 14:30
    This message was posted by a user wishing to remain anonymous

    There were a few articles on cybersecurity, digital health, and software as a med device in the global quarterly article series. How are regulatory bodies keeping up with and addressing artificial intelligence and machine learning?


  • 28.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:40

    "Artificial Intelligence and Machine Learning in Software as a Medical Device" is a hot topic! 

    FDA recently posted an discussion paper and call for feedback to industry about this exact theme HERE

    RAPS also posted an article that was super helpful and talks about that letter (I believe it's open source for everyone, even if you're not a RAPS member) HERE



    ------------------------------
    Allison Komiyama
    AcKnowledge RS
    San Diego CA United States
    www.acknowledge-rs.com/regulatoryaf
    ------------------------------



  • 29.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:50
    ​As you are aware, this is a rapidly evolving area and the Regulatory Health Authorities are definitely making a priority of how to address from a regulatory stand-point. For example, the FDA recently issued their Digital Health Plan to outline their approach to address some of these topics. I suspect this will be an area of substantial regulatory change, including the next reauthorization of PDUFA.
    There have been recent FDA press releases and news announcements describing how the agency is also conducting their own initiatives in the areas of AI (for pharmacoviligance monitoring) and various trials using RWE.

    ------------------------------
    Emily Huddle
    ------------------------------



  • 30.  RE: Global Regulatory Strategies and Best Practices Ask Me Anything Session

    Posted 12-Jun-2019 14:42

    Thanks for joining us for this wonderful session, and a big thank you to our experts Allison, Emily, Kirsten, and Melissa!

    As a reminder, you can find the Regulatory Focus Article Series, "Global Regulatory Strategies and Best Practices," here.

    Feel free to keep the conversation going by adding your question to this thread.

    Thanks again!

    Emily



    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------